ERIC Urges DOL to Exclude Large Plans from Fee Disclosure Guides

The ERISA Industry Committee (ERIC) recently urged the Department of Labor (DOL) to exclude large plans from its proposal to require service providers to distribute a guide or similar tool to fiduciaries in order to satisfy the disclosure regulations under section 408(b)(2) of the Employee Retirement Income Security Act.

The DOL in March 2014 proposed to collect information in order to explore the current practices and effects of the 408(b)(2) regulations and evaluate the need for a guide to help plan fiduciaries understand the information being disclosed to them. The DOL indicates that it is planning to conduct focus groups on small retirement plans. ERIC’s letter expresses concern that the DOL’s focus on small plans may cause it to assume that similar issues exist for large plans.

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